Slavery Act of this Era

Prime-Counsel PLLC (the Firm or we), a limited liability Company, is a law firm authorized and regulated by the American Bar Association of the United States. Prime-Counsel PLLC, is a global legal services provider comprising legal practices that has separate legal entities associated to support and practice law for its client base.

As an office based business our supply chain includes facilities for the benefit of clients. Otherwise our supply chain is typical for a global legal service provider, involving supplies such as office goods and equipment and supplies connected with business development events hosted by the Firm, which may include training events.
We are committed to achieving the highest standards of ethical conduct and to ensuring that we, our lawyers, employees and others who may provide services to the Firm or on the Firm's behalf, act in compliance with all applicable laws, which includes applicable laws prohibiting slavery and human trafficking.

We value our people and seek to create a work environment where everyone is treated with dignity and respect and in which diversity is valued. Everyone has a right to work without fear of harassment and we encourage reporting of inappropriate behavior and operate a strict policy of non-tolerance towards victimization of anyone making a report, in good faith. We do not engage with suppliers whom we know fail to operate to similar ethical standards and treat their staff with respect.

In line with our legal and ethical obligations we continue to address slavery and human trafficking risks in our business and supply chain and remain vigilant regarding such risks although they are ameliorated by the nature of our business, our long standing relationship with key suppliers and our processes regarding new suppliers. In the year ending 2015 we have:

Identified, on a risk-approach basis, suppliers in areas of perceived greater risk (for example, security, catering and cleaning). When we meet those suppliers, modern slavery concerns or breaches are addressed. Should any issues be reported, in particular any breaches, we would require them to be dealt with swiftly and appropriately.
Required our new suppliers, when first added to our system as suppliers, to complete a supplier information form, which contains a statement by the relevant supplier affirming compliance with applicable modern slavery laws.
Continued with awareness raising in our business by:
- continuing to include, as part of our training materials for new joiners, an information pamphlet on Modern Slavery;
- continuing to ensure that modern slavery issues and concerns are included in periodic meetings for managers and others involved in procurement;
- having updated our procurement guidelines and reflecting the requirements of the Modern Slavery Act 2015 in our key supplier contracts.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 with respect to the financial year ending 2019 and sets out the steps the Firm has taken in that period to continue to address slavery and human trafficking risks in our business and in our supply chain.

Outside of the United States Jurisdiction of our International Clients and Cases:

Prime-Counsel PLLC offices outside the U.S. do not supply goods or services in the U.S. independently. They are therefore not required by the Act to publish an annual statement. But since they supply services to Prime-Counsel PLLC, they have been treated in the same way as the firm’s other suppliers.

As a professional services provider, Prime-Counsel PLLC predominantly employs and contracts the services of professionally qualified people. The firm also contracts office support services including for catering, office supplies, IT, recruitment, property, cleaning, security, maintenance and construction services. Prime-Counsel PLLC suppliers outside the U.S. are primarily other Prime-Counsel PLLC offices which in turn contract a similar range of support services locally.

Our Modern Slavery Policy

Prime-Counsel PLLC has adopted and promulgated a Modern Slavery Policy (the “Policy”). This commits the firm to preventing any slavery in its business and requiring the same standards of its suppliers. The Policy applies to all employees, associates, and partners (“Prime-Counsel PLLC Personnel”) and to all those who perform services for or on behalf of Prime-Counsel PLLC. The partners of the firm have overall responsibility for the Policy. They have delegated responsibility for overseeing, evaluating and updating it to the Compliance Officer for Legal Practice.

The Policy makes clear that in addition to penalties that may be imposed by law on individuals or on Prime-Counsel PLLC, any Prime-Counsel PLLC Personnel who violate the Policy will be subjected to disciplinary measures up to and including termination of employment. Prime-Counsel PLLC may seek to terminate its relationship with any supplier that is found to be in violation of the Policy. Prime-Counsel PLLC will refer all appropriate matters to the enforcement authorities.

Prime-Counsel PLLC Personnel and suppliers are held responsible for reporting at the earliest opportunity any activity that might lead to, or suggest, a breach of the Policy in any part of the firm’s business or supply chains. The firm is committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that slavery of whatever form is or may be taking place in any part of the firm’s business or in any of its supply chains, including if the report is mistaken.

The Policy sets out requirements for regular training, assessing risks, due diligence procedures, performance indicators and an annual review. These are addressed below.

Due Diligence Procedures

Prime-Counsel PLLC aims to partner with suppliers committed to the same strict principles and high ethical standards that the firm adheres to itself.

The firm has designed due diligence procedures to establish, assess, monitor and reduce areas of potential risk in its business and supply chains, and to address any reports of slavery occurring. As the basis for these procedures, the firm first ensures that it can account for each step of its supply processes and that it knows who is providing goods and services to it at all times.

The firm takes the following actions with respect to all its direct suppliers in the United States and Outside of the U.S.

when entering into arrangements with new suppliers, the firm assesses them for any indicators that slavery might occur in their business or their supply chains;
suppliers are given a copy of the firm’s Modern Slavery Policy and informed in writing that the firm does not tolerate any form of slavery in their business or in any part of their supply chains;
suppliers are asked to sign the firm’s Supplier Code of Conduct to acknowledge that they are working on the basis required by the firm. This sets out fundamental ethical requirements that they should adhere to, including that they will not use any form of forced, bonded or child labor, and requires that they impose equivalent standards on their own suppliers. In the case of suppliers of professional services, this requirement is met by the inclusion of relevant provisions in the letters of engagement;

the firm imposes contractual obligations on suppliers requiring that they comply with the firm’s Modern Slavery Policy and Supplier Code of Conduct and warrant that their business and, to the best of their knowledge, their own supply chain do not use slavery. They may also be required to provide a statement to the firm setting out the actions they are taking to prevent any occurrence of slavery. The firm will review all responses and take appropriate follow-up action to resolve any concerns that may arise;

the firm reserves the right to audit any of its suppliers and, as appropriate, will require them to take specific measures to ensure that the risk of slavery is significantly reduced. In cases where slavery is identified, the firm requires that immediate remedial action is taken to address it and will provide appropriate support to achieve the safest outcome for potential victims. The firm expects its suppliers to engage constructively and responsibly, and to remedy any issues in a timely manner. In the event of failure to resolve the situation rapidly and satisfactorily, the firm will terminate the contract;
in the event of any allegations emerging of slavery occurring in a part of the firm’s supply chain, including from whistle-blowers, the firm will comprehensively and urgently investigate any such allegations and, if any slavery is identified, will take immediate action as set out above.

Risks

As a result of conducting these due diligence procedures, the firm continues to assess the risk of slavery in its own business as very low, particularly since its recruitment procedures, employment terms and internal policies are maintained and implemented in full compliance with all applicable employment laws and regulations. The firm invests heavily in the professional development, health and well-being of all its staff. We pay all employees in the office above Living Wage (except for our two-week vacation students, who receive an allowance).

The risk of slavery in the firm’s supply chains continues to be assessed as low, with the principal area of risk residing in the supply chains of the firm’s direct suppliers and contractors of office support services, particularly those in higher-risk jurisdictions outside the UK. This risk is managed through the due diligence procedures set out above.

For the financial year covered by this statement, the firm did not identify any incidence or significant risk of slavery in its business or supply chains. But it is fully recognized that this task requires constant vigilance.

Training

In accordance with the firm’s Policy, relevant staff in Human Resources, Facilities Management, IT, Finance, Marketing and Administration have received appropriate training and awareness-raising on the global and U.S. challenges posed by slavery, the requirements of the Act, the firm’s Policy and the implementation of the due diligence procedures. Discussions held during the training were taken into account in the development and improved implementation of the Policy. All staff have been briefed on the main requirements of the Policy.

Effectiveness

We have assessed the firm’s performance over the financial year covered by this statement against the key performance indicators defined in the Policy as follows:

a) The firm’s recruitment, employment and internal policies remain in full compliance with all applicable laws and regulations.

This was fully achieved.

b) All new suppliers sign the firm’s Supplier Code of Conduct.

All of our new suppliers signed the Code.

c) All suppliers respond satisfactorily to the firm’s request for a statement on their actions to prevent slavery and any concerns are satisfactorily and promptly resolved.

The firm did not have cause to require such a statement from a supplier. We are continuing to be alert to a need to exercise this requirement in reviewing new suppliers and those subject to contract renewal.

d) Any concerns raised as a result of audits or allegations are promptly followed-up and resolved.

The firm did not have cause to conduct an audit and no allegations were made. We remain alert to the potential need to conduct audits or to investigate allegations.

e) All relevant staff in Human Resources, Facilities Management, IT, Finance, Marketing and Administration receive appropriate training and awareness-raising.

This was fully achieved. The firm is continuing to develop awareness of slavery-related issues amongst relevant staff and with key suppliers.

Prime-Counsel PLLC continues to look for ways to improve on these actions to ensure that our Policy and its implementation are robust, effective, proportionate and focused on identifying and rapidly addressing the risks of slavery wherever they occur in our business or supply chains. Options under active consideration include:

requesting all our major suppliers to confirm on an annual basis that they are in full compliance with our Policy;
imposing the same requirements on our significant global suppliers as we currently apply to our U.S. suppliers;
establishing a Steering Group, meeting quarterly to pro-actively oversee the implementation of the Policy;
partnering with more community organizations such as Business in the Community and Working Families;
exploring accreditation as a Living Wage Employer;
incorporating training on the Policy into the induction training for all new staff and conducting annual awareness-raising sessions for all staff.

We aim to report progress on these and other potential developments in our future statements. Thank You.

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